Heuton v. Ford Motor Co., No. 18-2130 (8th Cir. 2019)
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The Eighth Circuit affirmed the district court's grant of summary judgment for Ford on plaintiff's claims of disability discrimination and retaliation under the Missouri Human Rights Act (MHRA). Plaintiff, born without a left forearm and hand, applied for an entry-level assembler position at Ford's assembly plant.
The court held that the district court did not err by using the broad-range-of-jobs standard because this case only involved the major life activity of working or employment; the district court did not err in concluding that plaintiff had not satisfied the broad-range-of jobs standard because Ford considered him permanently restricted from a single, particular job he applied for; plaintiff waived his argument regarding direct evidence of discrimination; and therefore plaintiff's claim of discrimination under the MHRA failed, because plaintiff failed to show that Ford regarded him as having a disability. Finally, the court declined to consider the retaliation claim on appeal.
Court Description: Shepherd, Author, of Melloy and Grasz, Circuit Judges] Civil case - Missouri Human Rights Act. Under the MHRA, even if plaintiff has shown that he has a physical limitation, he must nevertheless show Ford wrongly believed that his physical impairment (here the absence of a left hand) substantially impaired a major life activity; because this case only involves the major life activity of working or employment, the broad range-of-jobs standard applied, and the district court correctly applied that standard; the district court did not err in concluding Ford only considered plaintiff as unable to perform the single, particular job he applied for - entry-level assembly on an assembly line; plaintiff waived the argument that Ford was precluded from relitigating the issue of whether it regarded him as significantly restricted from performing either a class of jobs or a broad range of jobs in various classes because the issue was not raised before the district court; plaintiff presented no meaningful argument in this appeal regarding his retaliation claim, and the court would not consider it.
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